I wonder which Part of the FAR's is N194 operating for hire and reward
Also which FAA regional office hold their certificates
No FAA AOC... the aircraft is leased to a foreign air carrier, with the lease tailored to comply with 14CFR91 and 14CFR125, common with some business jets.
A loop-hole?
Yes, I expect so.
Also, I was told that the aeroplane is in remarkably good condition, and proved quite reliable during Hajj flying.
Dunno for sure, however.